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Eco-Design Directive
(EuP):
Analysis of the Standby/Off Mode
Implementing Measure
Intertek
70 Codman Hill Road, Boxborough, MA 01719
www.intertek-etlsemko.com/EuP 1-800-WORLDLAB [email protected]
Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
Introduction
The Eco-design Directive for Energy-using Products (EuP) 2005/32/EC
requires manufactures and importers to demonstrate compliance with the
Directive’s product-category-specific requirements outlined in so called
Implementing Measures (IMs). The EuP Directive is CE Marking legislation
and differs from other EU legislation as it’s intended to encompass the entire
life cycle of energy using products.
The Directive’s IMs provide the specific compliance requirements, segmented
by approximately 30 product categories with the promise of more product
categories to be identified in the future.
On January 7, 2009 the EuP Directive’s first IM (Standby/Off Mode power)
became the first enforceable IM under the EuP Directive. The intent of the
Standby/Off Mode IM is to reduce the energy consumption of household and
office products in standby and/or off mode power settings.
Table of Contents
1. The Eco-design Directive EuP ..................................................................... 3
Purpose and background of the Eco-design Directive .............................. 3
What is eco design? ................................................................................. 3
What will the Eco-design Directive mean to the consumer? ..................... 4
Criteria’s for selection of product categories ............................................. 4
2. Products covered by the Eco-design Directive............................................. 5
Product groups ......................................................................................... 5
Standby/Off mode..................................................................................... 8
How will the Directive be enforced?.......................................................... 8
Critical Dates for Standby/Off Mode ......................................................... 9
4. How to fulfil the requirements of the EuP Directive and stand by/off mode
requirements for legal CE Marking................................................................... 9
Services to help you handle EuP .............................................................. 9
For more information...................................................................................... 10
APPENDIX 1 Products Subject to the EuP Directive’s Standby/Off Mode
IM............................................................................................................ 12
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
1. The Eco-design Directive EuP
The Eco-design Directive for Energy-using Products (2005/32/EC) was
adopted in 2005 and came into force in August 2007. It establishes a
framework under which manufacturers of energy-using products (EuP) will, at
the design stage, be obliged to increase energy efficiency and reduce
products’ negative environmental impacts. While the Directive itself is a
framework, it makes specific provisions by product category called
implementing measures (IM). Each IM is adopted and published as an
individual regulation which, together with applicable harmonized standard,
provides the necessary conformity assessment regimen for a particular
product category. Each implementing measure’s conformity assessment
regimen covers minimum energy performance standards and environmental
regulations by product category.
Purpose and background of the Eco-design Directive
The purpose of the EuP directive is to decrease the environmental effects and
to promote environmental sustainability. Long term the aim is to support a
secured energy supply and promote sustainable development. Uniquely, the
Directive goes beyond energy efficiency into the entire product lifecycle and
accounting for total lifecycle cost. The Directive aims to benefit both Business
and Consumers with better, more efficient products, an improved
environment, and reduced product lifecycle costs with a more rational use of
resources.
The EU has determined that Energy-using products (EuPs) account for a
large proportion of the total consumption of natural resources and energy
within the Community.
In fact, a preparatory study showed that in 2005, standby and off mode power
functionality existed in nearly 3.7 billion products across the EU, consuming
47 TWh (Terra-Watt hours) in standby and off mode settings for a cost of €6.4
billion ($8.4 billion USD). By 2020 it is anticipated that the number of products
with standby and off mode settings will increase with 24% to 4.6 billion
products. Clearly the environmental impact of electricity consumption in
standby / off mode is significant.
What is eco-design?
Eco design is a concept at product design which aims to reduce the overall
environmental impact of a given product in various ways. This could translate
to something as unique as placement of a TV’s on/off switch – thus making it
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
easier or more difficult to shut down and save energy – or as straightforward
as the metals contained or how the various parts of a worn out product can be
recycled. Environmental performance and energy efficiency can be improved
by including environmental aspects at an early stage in the product design.
The EU’s definition of the Eco-design Directive
With the Eco-design Directive, the Commission has developed a coherent and
integrated framework: all environmental impacts of a product are taken into
consideration at once. This holistic approach aims at avoiding uncoordinated
action, which could lead to an overall negative result for the environment: for
example eliminating a toxic substance from a product might lead to increased
energy consumption, which on balance could have a negative impact on the
environment. The Eco-design approach also integrates other aspects of the
product into the analysis, such as functionality, safety, impact on health,
affordability for the consumer. For example, a greater energy efficiency of a
product should not result in a lower quality or a lower safety standard.
What will the Eco-design Directive mean to the consumer?
For the individual consumer, the Eco-design Directive will mean that the
products sold on the market will meet higher standards of, for example,
energy performance and other environmental factors. Certain implementing
requirements also contain requirements for information on such matters as
energy consumption and mercury content. The CE mark indicates that the
products meet the eco-design requirement.
Criteria for selection of product categories
There are many different product groups included in the EuP Directive. The
products should fulfil the following criteria in order to be included in an action
or to be self-regulating:
• The product should represent a significant volume of sales and trade
within the EU. Specifically, the total number of units on the EU market
for a given product type will exceed 200,000. For example, if there are
5 manufacturers of electrical product “X”, each with a EU distribution of
100,000 units. The total market volume for product “X” equals 500,000
units. Therefore, product “X” meets the market volume criteria for EuP
consideration.
• The product should, in view of the quantities put on the market and/or
used, have a substantial environmental impact within the EU.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
• There should be significant opportunities for improving the product’s
environmental impact without incurring unreasonable costs, in view of
the fact that:
• There is no other relevant common legislation for dealing with the
problem in a suitable manner and it cannot be solved by market forces.
• There is a large difference in the environmental performance of
different Energy using Products on the market with equivalent
functions.
A special method is used to assess whether and to what extent different
Energy using Products fulfil these criteria and to outline which eco-design
requirements can be established for each specific product.
2. Products covered by the Eco-design Directive
In principle, the Eco-design Directive applies to all Energy using Products
(except means of transport) and includes all energy sources.
The basic elements of the eco-design requirement are compiled by a number
of groups of experts engaged by the Commission, which then put forward
proposals for product requirements. The Commission reviews these on a
product-by-product basis and sends its proposals for product requirements in
a consultation document to all EU Member States.
Product requirements or so-called “implementing measures” are then
introduced for each product group through separate regulations which goes
directly into the national law of each member country under the Eco-design
Directive.
Product groups
The Directive will affect practically all products because requirements are
introduced for various product groups. Requirements for standby/off-mode
power functionality were the first to be issued and have been in effect since
January 2009. Other product groups adopted by the Commission are; street-
and office lighting, domestic lighting, simple set-top boxes and external power
supply units. To view an EuP timeline, please turn to page 7.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
The product groups currently under consideration or in effect are listed below
on the next page. The list conforms to the EU’s division of product groups into
lots of 1-27. Requirements which are approved will be examined by the EU
Parliament for at least three months before formal adoption by the
Commission.
Product Groups
Lot Product Category
1 Boilers (gas/oil/electricity)
2 Water heaters (gas/oil/electricity)
3 Personal computers and monitors
4 Imaging equipment: copiers, faxes, printers, scanners, etc.
5 Televisions
6 Standby and off-mode losses of Energy using Products
7 External power supplies
8&9 Street lighting and office lighting
10 Residential room conditioning appliances
Electric motors 0.75-375kW
Circulating pumps
11
Electric pumps
Ventilation fans
12 Commercial refrigerators and freezers
13 Domestic refrigerators and freezers
14 Domestic dishwashers and washing machines
15 Boilers for solid fuels
16 Domestic tumble dryers
17 Vacuum cleaners
18 Complex set-top boxes
18a Simple set-top boxes
Domestic lighting I
19
Domestic lighting II (reflector lamps and electric fittings)
20 Radiators and fan-heaters
21 Appliances for room-heating using hot air
22 Ovens for household and commercial use
Cooking ranges and grills for household and commercial
23
use
Washing machines, tumble dryers and dishwashers for
24
commercial use
25 Coffee machines
26 Network stand-by
27 UPS for household use
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
The Commission has also put forward a proposal to extend the Eco-design
Directive to what it refers to as “energy-related products.” This would include
products which affect energy consumption without themselves using energy,
such as car tires or windows.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
3. Standby/Off Mode Power Implementing Measure (IM)
The product requirement for standby and off-mode losses was adopted by the
EU Commission on 17 December 2008 and applied from 7 January 2009. The
unique aspect of standby/Off mode is that it does not include a special product
area, but embraces over a number of product groups, also known as a
horizontal product group.
Computers, microwave ovens, hi-fi equipment, televisions, DVD players,
digital set-top boxes and other products which remain in standby/off-mode
(i.e., the apparatus is connected to an electrical supply, but is in off mode)
consume energy despite the fact that they are not actually being used. In
many cases, products are not even equipped with an on/off switch.
Standby/Off mode
These regulations establish requirements for eco-design for electricity
consumption in standby/Off mode. The regulations apply to electrical and
electronic domestic and office use products. See appendix 1, page 12.
Power consumption by a product in standby/Off mode may not exceed 1.0
Watt one year after the regulations have come into force. After four years, the
highest permitted limit will be 0.5 Watt. Higher values may be permitted for
special functions. See below table for limits.
Some companies already meet the proposed requirements for standby/off
mode, whereas changes in construction and production may be required in
other cases. The requirement for standby/Off mode may be replaced by
specific EuP requirements set forth in the IMs for specific product categories,
such as digital set-top boxes or televisions.
How will the Directive be enforced?
Market surveillance will be conducted via market sampling and lab testing.
Compliance will be determined if the tested samples’ values do not exceed
10% of the limit values set forth in the IM.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
Critical Dates for Standby/Off Mode
> Power consumption data in Watts rounded to the second decimal place
By January 7,
Off Mode not to exceed 1.00W consumption
2010:
By January 7, Standby Mode not to exceed 1.00W; or 2.00W if providing
2010: information or status display
By January 7,
Off Mode not to exceed 0.50W consumption
2013:
By January 7, Standby Mode not to exceed 0.50W; or 1.00W if providing
2013: information or status display
4. How to fulfil the requirements of the EuP Directive and
stand by/Off mode requirements for legal CE Marking
There are two ways to show that you fulfil the requirements of the Eco-design
Directive. The first is through an environmental management system (the
equivalent of ISO 14001 or EMAS), which covers all the technical
requirements. The second is through a so-called “internal design control”
where each product is verified individually using testing methods. Regardless
of which option you choose, you must have the technical documentation to
prove the implementing measures have been fulfilled, a Declaration of
Conformity and CE Marking.
Services to help you handle EuP
Intertek’s EuP Compliance Program: A GREENER way to market
The EuP Directive is an expansive piece of environmental legislation; and if
taken on alone by manufacturers can seem onerous to achieve and difficult to
document compliance for legal CE Marking. Intertek’s depth of experts in
environmental legislation and product compliance have untangled the EuP
Directive and its implementing measures to help manufacturers realize the
most cost-efficient, easy to understand and simple path to compliance and
market access.
Intertek’s EuP solutions are broken into two categories:
1) EuP Training & Consulting
• EuP Training & Consulting: Learn WHAT your quickest and most
cost-efficient compliance options are. We’ll tell you IF, WHEN, and
HOW EuP will affect your product.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
• EuP Eco Software Analysis: Let Intertek perform an analysis of your
product’s Ecological profile (Life Cycle Analysis) according to the EuP
directive specifications.
2) EuP Compliance
• EuP Pre-Compliance Verification: Learn how your product measures
up against proposed and future EuP regulations for R&D purposes,
compliance planning and to determine market readiness.
• EuP Compliance Verification: Receive full verification to the
appropriate EuP Implementing Measures and we will deliver a test
report for your product’s technical file and Statement of Compliance for
legal CE Marking.
Quality and Environmental Management Systems and EuP: In addition to
third-party testing, the EuP Directive allows for compliance via a
manufacturer’s own Environmental or Quality Management System approach.
For this, manufacturers must still meet the conformity assessment
requirements of the applicable Implementing Measures. In short,
manufacturers must still have the appropriate testing and eco-design data to
support a compliance claim. But, manufacturers must have documented
processes within current EMS or QMS. Intertek can support manufacturers
with guidance on structuring their EMS or QMS to facilitate internal testing and
proper documented procedures for EuP compliance and technical file
preparation, or provide support with the actual testing and Statement of
Compliance.
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
For more information
If you have any questions or would like to start a new project, contact your
local Intertek account manager or call any of the numbers below.
Americas Germany Sweden
+1 800 967 5352 +49 711 27311 0 +46 8 750 00 00
info.etls-[email protected][email protected][email protected]
Asia Pacific Italy UK
+86 21 6495 6565 +39 432 653 411 +44 1372 370900
info.etls-[email protected][email protected][email protected]
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Eco-Design Directive (EuP):
Analysis of the Stand by/Off Mode Implementing Measure
APPENDIX 1
Products Subject to the EuP Directive’s Standby/Off Mode IM
HOUSEHOLD APPLIANCES IT and CONSUMER EQUIPMENT
Washing machines ITE equipment primarily for domestic
use
Defined as ‘any equipment which has a
primary function of either entry, storage,
display, retrieval, transmission,
processing, switching, or control, of data
and of telecommunication messages or
a combination of these functions and
may be equipped with one or more
terminal ports typically operated for
information transfer’
Clothes dryers Radios
Dish washing machines Televisions
Electric ovens Video cameras and recorders
Hot plates Hi-fi recorders
Microwaves Audio amplifiers
Toasters Home theatre systems
Fryers Music instruments
Grinders, coffee machines and Any other equipment for the purpose of
equipment for the opening or recording or reproducing sound or
sealing containers or packages images, including signals or other
technologies for the distribution of sound
and image other than by
telecommunications
Electric knives Toys, leisure and sports equipment
Other appliances for cooking, Electric trains or car racing sets
food processing, cleaning,
clothes maintenance; appliances
for hair cutting, hair drying, tooth
brushing, shaving, massaging
and other body care appliances
Scales Hand-held video game consoles
Sports equipment with electric or
electronic components
Other toys, leisure and sport equipment
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